Today we received two more good comment letters sent in from Maui and Oahu, but wanted to get one more of Hope's up and then will post those. The following are Hope Kallai's of Kauai comments on the Act 2 Pseudo-'EIS'. Still have four more letters of Hope's to do beyond this. This letter is of comments regarding impacts on safety, security, and public health:
23 February 2009
Katherine Kealoha, Director
Hawaii Office of Environmental Quality Control
235 S. Beretania St., Suite 702
Fax: (808) 586-4186
Michael Formby, Deputy Director
Hawaii Department of Transportation, Harbors Division,
79 S. Nimitz Highway,
Fax: (808) 587-3652
RE: Comments for Inclusion
Draft Environmental Impact Statement (DEIS)
Large Capacity High Speed RO PAX ferry Alakai, Hawaii Superferry, Inc.
Impacts on Safety and Security and Public Health
Aloha Director Kealoha and Deputy Director Formby:
Mahalo for the opportunity to include comments for inclusion to the DEIS on potential impacts by the operation of large-capacity, high speed RO PAX interisland ferries, especially considering the operation by the Hawai`i Superferry, Inc. (HSF) and the wave-piercing catamaran Alakai. I am very concerned about the impacts of the arrival of this unsecured vessel in our ports. The DEIS needs to address safety issues from the presence of this new mode of transportation.
The Federal Bureau of Investigation has identified ferry systems as the number one potential maritime terrorist target in the U.S. An attack on one of the larger commuter boats could result in a higher number of deaths than an attack on commercial aircraft or trains. Ferries are also continually at risk of an accident or a natural disaster. Security of our ports is a high priority of the Department of Homeland Security from both terrorism and organized crime since the terrorist attacks on Sept. 11, 2001:
"'The threat to ferries is real and we must reduce their vulnerabilities,' said Capt. Frank Sturm, chief of the Coast Guard’s office of port, vessel and facility security."
Large passenger ferries pose the greatest risk of terrorism in maritime transportation, warn the U.S. Coast Guard and Department of Homeland Security.
According to a Coast Guard study, large ferries received the highest risk assessment score among 80 maritime terrorist scenarios (tying with a ship carrying hazardous cargo near an urban area) because they can confine a thousand people in one space far from land and have little or no passenger screening. Many state ferry systems have instituted TSA type screenings, with bomb-sniffing dogs inspecting every passenger and many have FBI VIPER teams.
According to the August 2008, Rapid Risk Assessment of Operational Compliance and Environmental Risks of the Hawaii Superferry (HSF) prepared by Belt Collins for the Hawaii Department of Transportation, Harbors Division:
· 17% of passengers (without vehicles) were not screened nor asked about possession of prohibited items.
· 23% of vehicle interiors were not inspected.
· 30% of vehicle wheel wells were not inspected.
Only luggage, coolers, and vehicles are checked. Whatever is carried on the person goes uninspected. Conditions imposed by Governor Linda Lingle in Executive Order No. 07-10 include the visual inspections and agricultural screenings of all vehicles including engines, interiors, undercarriages, wheel wells, trunks, beds of pickup trucks, trailer equipment and vehicles, and that unscreened vehicles will not be allowed to board. The DEIS needs to address the gaps in the inspection program and the RRA cited non-compliance with EO 07-10. The impact of weapons and restricted items (including drugs) concealed on passengers bodies must be addressed.
In Honolulu Port & Harbor Security, Paul S. Schultz states:
"The State of Hawaii is unprotected and exposed with limited surveillance of its ports, critical infrastructure and borders, where:
•Majority of necessary goods are shipped through the Ports
•High potential for severe natural disasters
•No comprehensive port or port approach surveillance capability
•No coordinated or centralized monitoring at the county or state level
Maritime Security Plan (MSP) priorities include real-time surveillance of critical harbor infrastructure and tracking of all waterborne traffic within this area and the prevention and detection of potential IED attacks by small watercraft. Existing security capacity does not mitigate the vulnerabilities that could cause loss of life, threaten critical infrastructure and/or take down the economic lifeline of the State of Hawaii."
The DEIS needs to address the safety and security of our ports and islands when impacted by an unsecured new mode of high speed transport. The DEIS, as prepared, seems to consider security concerns as traffic issues, and hiring security guards and off-duty police for traffic control as sufficient. Vehicle inspections are scheduled to end in early 2009 and be only sporadic. This is unacceptable. Every vehicle must be inspected, during daytime and under fully light conditions. The DEIS must consider potential security risks to our military bases and infrastructure and threats to the public...by this new mode of inter-island unsecured transportation.
Attached please find a copy of the letter from Rear Admiral M. K. Brown, of the Fourteen Coast Guard District, that is included in Appendix A (A-1-12) of the Statewide Large Capacity Interisland Ferry DEIS. Excerpted from Rear Admiral Brown:
"The Coast Guard has an interest in protecting the safe navigation and the free flow of commerce, and has manifested this interest in the Hawaii Superferry case by issuing security zones. Federal law (NEPA) requires an independent assessment of the environmental impacts, if any, of these security zones…"
Rear Admiral Brown is right. The impact of the security zone is significant and deserves a “hard look” under NEPA. The DEIS should request a EIS to be prepared by the U.S. Coast Guard on the direct, indirect, cumulative, and secondary impacts of the implementation of security zones in the Hawai`i harbors of Nawiliwili, Honolulu, Kahului and Kawaihae and the impacts of a class of one private company monopolizing the use of large sections of our already crowded harbors. Deliveries of bulk containers of grain, cement and fuels must not be forced to wait on casual ferry operations. HSF should not be allowed to unilaterally determine the frequency and timing of their interrupting operations in the State's harbors. If HSF decided to increase operations to 4 trips per day, our harbor commerce would be severely impacted.
The DEIS needs to address Passenger and Port Safety with regard to fire suppression. Whose kuleana is it to fight fires on HSF in port? In the open ocean? Are there any emergency rescue boats that can assist in evacuation of this type of vessel?
In Appendix A. Contacted Parties, there seems to be a lack of contact with local Civil Defense agencies. The DEIS needs to include comments from county Civil Defense authorities, with clear determination of leadership roles and kuleana. The impact of unsecured vessels in our ports is significant and must be considered in the DEIS. Please contact proper local civil defense for comments.
The DEIS needs to address procedures concerning medical emergencies at sea. The DEIS must address rescue coordination with county Water Safety Divisions. Are extremely gravid women allowed to travel and is there a plan for delivering babies? The DEIS needs to address medical emergency evacuation plans, including helicopter and sea assists.
The DEIS needs to address Passenger Safety during emergencies. There are only 2 fast rescue lifeboats on the Alakai, a vessel carrying 903 people (including crew and support). There are no Marine Evacuation System (MES) slides from this tall vessel.
In Hawaii Superferry Environmental Commitments and Actions, HSF states that, “it has Advanced Lifesaving Equipment and that no loss of life has occurred on these types of vessels.” In the RAPID RISK ASSESSMENT OF OPERATIONAL COMPLIANCE AND ENVIRONMENTAL RISKS OF THE HAWAII SUPERFERRY prepared for State of Hawai‘i Department of Transportation Harbors Division, August 2008, pages 41-44, the Certificate of Inspection, United States Coast Guard, Department of Homeland Security, dated 24 May 2007, on the aluminum hull vessel Alakai, #1182234 (see Attachment #1) itemizes the on-board Lifesaving Equipment as follows:
· 948 life jackets for adults
· 87 lifejackets for children only
· 4 immersion suits
· 8 ring buoys
· 11 inflatable liferafts (certified for 100 people each)
There have been many advances in Lifesaving Equipment in the past century, including immersion suits and lifeboats able to withstand pretty extreme seas and weather...THE DEIS needs to address provisions of Advanced Lifesaving Equipment...and include Passenger Emergency Evacuation Information in the document.
It is not clear what “type” of vessel has not sustained losses of life. RO PAX vessels are among the highest risk type vessels, with a higher incidence of catastrophic losses including loss of life...
In their advertising, the HSF, Inc. advocates bringing children, grandparents, handicapped people and sick people to off-island doctor visits. The HSF ship has no slides for emergency evacuation of the vessel (Marine Evacuation Systems or MES). During emergency evacuation, passengers must jump off a 40 feet high ship and swim to a liferaft. Evacuation from that height would likely injure many people. How are children, kupuna and handicapped people supposed to disembark from 40 feet? Then, they are supposed to swim to a life raft? Is there a float chair for handicapped people? Are there chair locks available on the vessel? Are evacuation plans ADA compliant? These are not safe evacuation plans for open ocean water travel, with distances over 100 miles from ports. Many people panic when out of sight of land; for many, it would the first time on the open ocean. Emergency situations also generate panic. Are there ample crew to handle mass panic and emergency situations?
Richard Hiscock, a Cape Cod-based maritime safety consultant, points out that the Titanic survivors lived because lifeboats provided out-of-the-water protection, while the passengers floating in the water wearing lifejackets died of hypothermia. The water was freezing cold, with icebergs. Lifejackets and other safety devices that provide no protection from hypothermia should not be the only available equipment for babies, children, the elderly, the handicapped and able-bodied passengers who must jump overboard, he says.
Even in Hawaii's ocean waters the threat of hypothermia exists. Hypothermia can happen when the body temperature drops below 95 degrees Fahrenheit and the body loses heat faster than it is producing it. Panic exacerbates hypothermia, drastically reducing open water survival time. When the body core temperature drops to about 87 degrees, the average person will lose consciousness and drowning is imminent. Pacific Ocean water temperatures range from 70 to 85 degrees Fahrenheit. In addition, a sudden, unexpected entry into water may cause a reflexive "gasp" allowing water to enter the lungs. Many people “loose their breath” and panic when jumping from over 15 feet heights. Drowning can be almost instantaneous.
Your body cools down 25 times faster in water than in air. Temperature, body size, amount of body fat, general health and movement in the water all play a part in open water survival. Small people cool faster than large people and children cool faster than adults. People with impaired circulation, diabetes, chronic diseases and physical impairments have reduced rates of survival.
RO PAX vessels are a relatively new form of water transportation. Safety regulations have changed as often as hull designs. Disembarking from great heights during emergency situations is extremely dangerous; elsewhere in the world, volunteers and crew members have been killed during escape/rescue drills. Use of fast rescue boats is also very dangerous, so dangerous that Europe has outlawed their use in RO PAX ferry rescues. Amendments to part A of the STCW Code, also entering into force on 1 January 2008, add additional training requirements for the launching and recovery of fast rescue boats. The amendments were adopted in response to reports of injuries to seafarers in numerous incidents involving the launching and recovery of fast rescue boats in adverse weather conditions.
The Hawaii Superferry has met minimum Coast Guard standards. Minimum standards do not guarantee highest survivability... The DEIS needs to address alternate methods of emergency rescue with the main priority being the greatest preservation of public safety.
RO PAX ferries have experienced flooding events from extreme precipitation and huge waves overtopping vessel height and flooding vehicle decks and combinations of wind, waves, and precipitation. Rain water drains onto the vehicle decks, into the gutters, and into the bilge water piping system. There are no scuppers draining bilge water from the decks into the ocean.
The Rapid Risk Assessment states that there is a 500 liter bilge water holding tank located in Void #7. I hope this is an error – the bilge water holding tank has to be larger than 500 liters! The DEIS needs to have correct facts concerning the bilge capacity and include vehicle deck drainage volume calculations.
Hawai`i experiences extreme precipitation events. Kaua'i has received 11 inches of rain in one hour. How much precipitation runoff can the area of the open vehicle decks receive? How much precipitation can the bilge system contain? It seems the safe travel of this vessel is based upon many conditions – not just the seas being less than 6 meters (19 feet). The DEIS needs to address precipitation-generated bilge overtopping situations and consider the impact to public safety and the inclusion of precipitation events in the determination of daily travel.
Worldwide "two large ships sink every week on average," said Wolfgang Rosenthal, of the GKSS Research Centre in Geesthacht, Germany. "But the cause is never studied to the same detail as an air crash, it simply is put down as 'bad weather.'" The DEIS must consider the rolling limitations of the Alakai due to extreme weather.
Besides overloading problems, most accidents on RO PAX ferries also occur because of:
· cargo shifting
· collision (other vessels or objects or ocean floor/shore)
Cargo shifting can occur because of improper loading, weather, spills and extreme sea conditions. Vehicles have already sustained damages on the Alakai from shifting. The Alakai has already sustained collision damage. Rain and large waves can fill the vehicle deck causing cargo shifting, so can leaks or spills from a vehicle. Cargo shifting can cause the ship to list, further take water and capsize. Some RO PAX ferries can capsize with less than 6 inches of water on the vehicle deck. Elsewhere there have been many fatalities in recent years from cargo shifts and vehicle deck flooding. The DEIS needs to address the safety of the public from cargo shifts and vessel flooding. If water is used for fire suppression, flooding can also result. Gasoline cans, propane tanks, and flammable materials are allowed transport in passenger vehicles. Commercial water and milk tankers could fill the vehicle decks. Loads and combinations are difficult to predict.
When RMS Titanic departed Queenstown on 11 April 1912 it carried 2,228 people: 1,343 passengers and 885 crewmembers. The vessel was equipped with 20 lifeboats of three different sizes designed to hold 1,178 persons – slightly more than one-half the number on board. Had Titanic been fully loaded – with the 3,547 people it was capable of carrying – there would have been lifeboats for less than one-third the number on board.
It is generally assumed, as a result of the Titanic disaster, that all passenger vessels are equipped with enough primary lifesaving devices (lifeboats or liferafts) – devices designed to prevent immersion in the water – for the total number of persons that can be carried onboard. The Alakai carries only 2 rescue boats, designed to assist evacuated passengers into liferafts. Would those liferafts be safe in 18 ft swells?
All vessels are required to carry life-jackets for everyone onboard. Life-jackets prevent drowning, but they do not prevent hypothermia – a lowering of core body temperature. The survivors of Titanic lived because they were out of the water. Those in the water perished in their life-jackets.
To prevent the lethal effects of hypothermia it is necessary to stay out of the water.
In a 1989 NTSB Safety Study entitled Passenger Vessels Operating From U.S. Ports the Board recommended that the U.S. Coast Guard:
"Require that ALL passenger vessels except ferries on river routes operating on short runs of 30 minutes or less have primary lifesaving equipment that prevents immersion in the water for ALL passengers and crew."
The Coast Guard did not implement the recommendations.
Unlike their U.S. counterparts, most passenger vessels in Canada have out-of-the-water equipment for everyone onboard. "I'd safely say that above 75% of Canadian passenger vessels have out-of-the-water equipment for 100% of the passengers," says Bud Streeter, director general of marine safety for Transport Canada. "In winter, all Canadian passenger vessels, except two in Vancouver's rapid transit system, have out-of-the-water equipment for everyone. And those two vessels have just received approval to install such equipment."
The Coast Guard rules are based on the probability that this will NOT happen. Industry argues that the cost is too high, and the odds of needing such equipment very low. What about the “cost” to the passengers and to the next-of-kin? What were the odds that Titanic would sink on her maiden voyage?
The NTSB “is disappointed that the Coast Guard has not acted on the recommendation” and “holds firm to its belief…that there must be 100 percent out-of-the-water survival craft for all passengers on all routes regardless of the temperature.”
The DEIS, and the Hawaii Superferry Company, Inc. need to consider Public Safety a high priority and exceed Coast Guard specifications before a catastrophe happens at sea.
Between 1989 and 1994, Lloyd's of London Register figures show that 4,583 lives were lost in accidents at sea. Of these, 1,544 were lost in accidents involving RO PAX cargo ships - exactly one third, even though RO PAX ships make up only a small fraction of world merchant marine tonnage. Although RO PAX ships are involved in an average number of accidents, the consequences of those accidents are usually far worse.
A RO PAX study was compiled by the classification society det Norske Veritas in 1983 by the IMO in Norway, covering the years 1965-1982. Of 341 accidents during the period, 217 were defined as serious and 36 resulted in the total loss of the RO PAX vessel:
ROPAX Accidents ---- Serious ------ Total Loss Accidents
collisions -------------- 24% ---------- 25%
machinery damage -- 17%
grounding ------------- 17%
cargo shift & ops ----- 16% ----------- 43%
fire and explosion ---- 14% ----------- 18%
The paper noted:
· >70% RO PAX total losses due to collision resulted in loss of lives
· 60% of ships capsizing following a collision sunk in 10 minutes
The dNV study showed that total losses as a result of a collision were much higher for RO PAX than for other ships (with only a 9% occurrence). Both collisions and uncontrolled shifts of cargo more frequently led to serious consequences with RO PAX vessels.
Even in the era of advanced navigation techniques, large vessel groundings are still occurring in Hawai`i:
· US Navy Port Royal damages coral reef off O`ahu Feb. 19, 2009. Ship had discharged 7,000 gallons of wastewater and marine diesel when it was grounded.
· July 1, 2005 NOAA-contract Research Vessel Casitas on Pearl & Hermes reef. The 145 foot RV Casitas, on a mission to remove marine debris from the Northwestern Hawaiian Islands, ran hard aground near North Island at Pearl and Hermes Atoll, 1,000 miles northwest of Oahu and 86 nautical miles east southeast of Midway Islands, causing severe damage to the ship and spilling oil into a designated marine reserve. The vessel was steaming from Midway to Maro Reef for further marine debris clean-up activity when it ran onto the reef. The vessel had 16 NOAA/Joint Institute for Marine and Atmospheric Research (JIMAR) divers from the Pacific Islands Fisheries Science Center (PIFSC) and a crew of 8 onboard.
The structural integrity of the vessels after sustaining collision damage needs to be seriously considered. The DEIS must consider the seaworthiness of this vessel and the impact to passenger safety. The US Coast Guard Certificate of Inspection criteria determine what seastates this vessel is rated for.
Over the last two decades more than 200 supercarriers - cargo ships over 200m long - have been lost at sea. Eyewitness reports suggest many were sunk by huge and steep walls of water that rose up out of flat seas.
Waves that come out of nowhere, sometimes in a relatively calm sea. Rogue waves. Beginning in the 1990s, sailors and scientists began to suspect that rogue waves were responsible for many more losses at sea than they had previously guessed...
Previously, data collected by weather ships suggested that such waves would occur only every 50 years or more. In 2004, the European Space Agency (ESA) used data from two radar-equipped satellites to see how frequent rogue waves actually are. After analyzing radar images of worldwide oceans taken over a period of three weeks, the ESA's MaxWave Project found 10 waves 82 feet (25 meters) or higher.
Ironically, while the MaxWave research was going on, two tourist liners endured terrifying ordeals. The Breman and the Caledonian Star cruiseliners had their bridge windows smashed by 30 ft waves in the South Atlantic. The Bremen was left drifting for two hours after the encounter, with no navigation or propulsion...
Other hard evidence of monster waves comes from instruments designed to measure wave heights. One such instrument was mounted on an offshore oil rig known as the Draupner Platform. On New Year's Day 1995, the platform was measuring waves no more than 16 to 23 feet (5 to 7 meters) high. Then it suddenly registered a single wave almost 66 feet (20 meters) high. Canadian weather buoys near Vancouver recorded waves 100 feet high and higher throughout the 1990s.
The DEIS must consider the potential impact on the Alakai of rogue wave strikes.
No alternate hull designs or sizes were considered in the DEIS, nor was the alternative of a passenger-only ferry considered. Smaller, slower and more appropriate hull designs should have been considered, as well as alternative, hybrid and combination fuel technologies. The DEIS should consider a No Vehicle Alternative, as well as No Passenger Vehicles (Commercial Only) alternative.
I am concerned about the use of the landing ramps and the use of tugboats to hold the barge/ramp in place, which invalidates the warranty and intended use of the ramps. Do the engineering studies reflect whether this is safe for public transit? The DEIS needs to address the question of whether using barges made in China are actually legal for commerce in Hawai`i.
The DEIS needs to address the recommended maintenance and inspection schedule for the barges, including how the barges will be hauled out, who pays for maintenance and insurance?
Hawaii County is rated 3rd in the US for earthquake risk (behind San Francisco and San Jose) and is the only county in the top 10 earthquake risk counties not in California. The largest earthquake potential is on the flanks of Mauna Loa-Kilauea (Magnitude 8) and Hualalai with up to Magnitude 7 events possible throughout Hawaii Island. Kawaihae Harbor has sustained major earthquake damage, and yet I see no seismic provisions in the DEIS. Impacts to projected infrastructure development from large earthquake events should be considered and safety plans developed in the DEIS.
The HSF expects to hit whales. What is the impact to the integrity of the ship after a whale strike? The DEIS needs to address the safety of passengers during the expected whale strikes and the safety of the ship post-strike. The rudder has sustained damages so severe that the overall fuel efficiency was reduced by 5%. The hull has also sustained severe damage. Is there a subsequent 5% reduction of structural integrity? How many more impacts of this nature can this vessel sustain?
The DEIS does not consider the impact to Public Health of the island residents and animals from the mixing of the communicable diseases and problems unique to each outer-island population. Outer islands have enacted different Dengue Fever restrictions. Avian flu must be considered.
The DEIS has no consideration for preventing the spread of rat lungworm disease that has recently surfaced on Hawaii Island and must consider the impact to public health and agriculture from the spread of these organisms.
Rat lungworm is caused by Angiostrongylus cantonensis, a parasitic nematode carried in the pulmonary arteries of rats. The rats excrete worm larvae in their feces, which are sometimes eaten by small snails and slugs that often nestle in the folds of lettuce, peppers and other produce. When people ingest the small worm, it travels from the gastrointestinal tract to the central nervous system and can cause meningitis, coma or even death. Parmarion martensi, a newly introduced snail, and semi-slugs are common hosts for the rat lungworm. The DEIS must address the potential spread of this Rat Lungworm as a public health risk and consider the potential impacts to the agriculture of our state and continue inspections of every vehicle and agricultural shipment to prevent the spread of infected snails, slugs and semi-slugs.
There have been recent instances of ships being turned away from ports because of sick people onboard, as with the Norwalk-like virus experienced on cruise ships. After allowing offloading of passengers on Kaua'i, a ship was turned away from docking on Maui and returned to Mexico. The DEIS should address ways to deal with public health problems like communicable diseases.
Many people have reportedly gotten seasick due to travel on the Alakai, which may mask symptoms of other communicable illness. Visibly sick travelers are barred from airlines. What provisions does HSF have for detection of communicable diseases from seasickness? Is there really time to disinfect the ship in between sailings?
Open oceans are full of rubbish - marine debris consisting of fishing nets lost or discarded at sea (ghost nets) by non-Hawaiian fishing vessels operating in waters far away from Hawaii. Some are miles long and are carried in the ocean currents for months or years where they become entangled in reefs of the Northwestern Hawaiian Islands and pose a significant threat to highly endangered Hawaiian monk seals and other marine life. For over a decade, NOAA has conducted marine debris clean-ups in the Northwestern Hawaiian Islands. Over 100 metric tons of debris have been collected and removed annually during these clean-up missions.
The DEIS should consider the impact of marine debris on the intake jets of the Alakai's propulsion system and to the safety of the passengers and crew.
Thank you for the inclusion of my comments in the DEIS.